The risk management program regulations require that an initial process hazard analysis (PHA) for each Program 3 process be completed no later than June 21, 1999 (or by the time the process first has more than a threshold quantity of a regulated substance, if that occurs after June 21, 1999) and updated at least once every five years. Does a PHA that was conducted for purposes of compliance with OSHA's Process Safety Management (PSM) standard satisfy EPA's PHA requirement for Program 3 processes? Would an OSHA PHA have to be revalidated before June 21, 1999 (or by the time the process is first subject to part 68) to address possible offsite impacts and qualify as the initial risk management program PHA?
If your Program 3 process is also subject to OSHA PSM, you can use the PHA conducted for OSHA PSM compliance as your initial process hazard analysis for EPA purposes, provided you conducted your initial OSHA PHA prior to May 26, 1997 (the date by which all initial OSHA PHAs must have been completed). In such cases, you can also update and revalidate your PHA on OSHA's schedule, but your update should consider offsite impacts. Any initial PHA performed after May 26, 1997 must consider offsite impacts in order for it to satisfy EPA's requirements.